ICBA submitted comments to the OCC on its notice of proposed rulemaking that would revise the supervisory framework for the issuance of matters requiring attention in response to violations of laws or regulations. ICBA said it supports the OCC’s effort to focus corrective actions on substantive violations rather than immaterial procedural findings, but it believes several aspects of the framework warrant further refinement to ensure it effectively distinguishes between substantive and technical violations and promotes a more consistent supervisory approach.